Justia California Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
Cervantes v. Bianco
A group of Riverside County residents, having voted in the November 2025 special election on Proposition 50, challenged the actions of the county sheriff’s department. The sheriff, responding to claims by a community group of a significant discrepancy between unofficial poll worker ballot intake logs and the Registrar of Voters’ final certified count, obtained search warrants and seized approximately 650,000 voted ballots. The Registrar of Voters maintained any discrepancy was minimal and within normal bounds, and no party disputed that the alleged discrepancy could not have changed the election outcome.After the sheriff’s department seized and began examining the ballots, the voters filed a petition for a writ of mandate directly in the Supreme Court of California. They argued the sheriff’s actions violated the Elections Code’s strict rules regarding the custody of ballots and requested the court order the immediate return of the ballots to the Registrar. The Registrar did not oppose this relief, and both the Secretary of State and Attorney General supported the petitioners’ position. The sheriff argued his actions were lawful as part of a criminal investigation supported by search warrants.The Supreme Court of California held that the seizure and removal of the ballots from the Registrar’s custody was unlawful under Elections Code section 15551, subdivision (d). The Court explained that the Elections Code specifically requires that voted ballots remain in the custody of the elections official at all times and that this rule applies even during criminal investigations. The Court issued a peremptory writ of mandate directing the sheriff to return all packages containing voted ballots to the Registrar and to refrain from further handling of the ballots, but denied the request for additional relief regarding non-ballot election materials and chain-of-custody reporting. The Court’s order superseded the previously issued superior court search warrants to the extent of any conflict. View "Cervantes v. Bianco" on Justia Law
P. v. Hazlett
In October 1978, a woman named Tana Woolley was found dead in her apartment in Rosamond, California. She had been strangled with a sock, and her body was partially undressed. Initial investigation yielded no arrests, although DNA and other forensic evidence were collected. Decades later, with advances in DNA technology, semen stains found on Woolley’s bedspread were tested and matched the defendant, who lived in the same apartment complex at the time. The defendant denied knowing Woolley or ever being in her apartment. Further investigation revealed he had previously committed multiple sexual assaults, and evidence of these prior offenses was admitted at trial.The case was first tried in the Kern County Superior Court. The jury convicted the defendant of first degree murder and found true two special circumstances: that the murder was committed during the commission or attempted commission of rape and burglary, both requiring a finding of willful, deliberate, and premeditated murder under the then-applicable 1977 death penalty law. At the penalty phase, the jury returned a verdict of death, and the trial court entered judgment accordingly. The defense raised several issues, including challenges to jury selection, the admission of prior sexual offenses, and various constitutional and evidentiary claims.The Supreme Court of California reviewed the case on automatic appeal. It addressed whether the defendant established a prima facie case of racial discrimination in jury selection, the admissibility and instructions regarding other sexual offenses, the sufficiency of the evidence for the murder and special circumstance findings, and challenges under the California Racial Justice Act. The court held that the defendant failed to establish a prima facie case of discrimination in jury selection, that the evidence and instructions regarding prior sexual offenses were properly admitted, and that sufficient evidence supported the convictions and special circumstance findings. It further determined that no prejudicial error occurred under the Racial Justice Act. The court affirmed the judgment of death. View "P. v. Hazlett" on Justia Law
P. v. Lightsey
The defendant was charged with capital murder and other offenses in 1993. Throughout the proceedings, concerns arose regarding his mental competency and his ability to represent himself. On two occasions, the trial court declared a doubt as to the defendant’s competency and held hearings, concluding both times that he was competent. During the second such hearing in July 1994, the defendant represented himself, which meant no counsel was appointed despite statutory requirements. The medical experts at the hearing offered differing views: one expert found the defendant competent to stand trial but not to represent himself, while the other found him unable to cooperate rationally with counsel. The defendant was ultimately convicted and sentenced to death.After direct appeal, the Supreme Court of California found reversible error in the trial court’s failure to appoint counsel during the 1994 competency proceedings and remanded the case, instructing the trial court to determine if a retrospective competency hearing was feasible. If feasible, a hearing would be held; if not, the reversal would stand.On remand, the Kern County Superior Court found that a retrospective hearing was feasible, conducted the hearing, and a jury found the defendant competent at the relevant time, leading to reinstatement of the judgment. The defendant appealed again, arguing that feasibility was not established.The Supreme Court of California held that the trial court erred in finding a retrospective competency hearing feasible. The court emphasized that such hearings are generally disfavored and that the prosecution had not met its burden to show sufficient and reliable evidence existed to determine the defendant’s competence nearly two decades later, especially given the unavailability of key witnesses and the compromised development of evidence due to the lack of appointed counsel in 1994. As a result, the Supreme Court reversed the reinstated judgment, subject to retrial if the defendant is then found competent. View "P. v. Lightsey" on Justia Law
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P. v. Shove
The defendant was convicted by a jury of the first degree murders of an elderly married couple who owned and operated an aerospace business. The prosecution’s evidence showed that the defendant masterminded a scheme to acquire the business for himself, which involved hiring an associate to kill the couple, burglarizing the company’s safe, and attempting to extort money from the victims’ children using stolen documents and threats under a false identity. The defendant’s efforts to obtain the business were persistent, and he was described as persuasive and intimidating, often referencing fictitious connections to organized crime. After the murders, forensic evidence connected the associate to the crime scene, and extensive phone records showed frequent communication between the defendant and the associate around the time of the killings. The defendant was also involved in the subsequent burglary of the business safe and in an extortion plot targeting the victims’ children.At trial in the Los Angeles County Superior Court, the jury found the defendant guilty of the murders, burglary, receiving stolen property, and extortion. They also found true the special circumstance allegations of multiple murder and murder for financial gain. The penalty phase concluded with a death sentence. The trial court denied the defendant’s motions for a new trial and to modify the verdict.On automatic appeal to the Supreme Court of California, the defendant challenged numerous aspects of the trial, including the denial of his motion to suppress evidence from a search of his home, the exclusion of third party culpability evidence, the admission of an audio recording and evidence of his use of an alias, several claims of prosecutorial misconduct, the exclusion of impeachment evidence, and issues related to the penalty phase, such as the admission and notice of victim impact testimony and the constitutionality of California’s death penalty scheme.The Supreme Court of California affirmed the judgment in its entirety. The court held that any errors in the admission or exclusion of evidence were either not prejudicial or were harmless beyond a reasonable doubt. The court also found no reversible error in the handling of jury selection, the exclusion of third party culpability evidence, or the penalty phase proceedings, and rejected the defendant’s constitutional challenges to the state’s death penalty law. View "P. v. Shove" on Justia Law
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Family Violence Appellate Project v. Super. Ct.
In this case, organizations that represent indigent and low-income litigants challenged the widespread unavailability of official court reporters in California’s superior courts for civil, family, and probate proceedings. These organizations documented that, despite prior assurances, many indigent litigants appear in court and find that no court reporter is present, even when properly requested. As a result, such litigants are often forced either to accept repeated continuances—delaying urgent matters like domestic violence restraining orders and child custody—or to proceed without a verbatim record, which severely impairs their ability to seek appellate review.Previously, the Supreme Court of California had ruled in *Jameson v. Desta* that when a superior court does not routinely provide court reporters in civil cases but allows parties who can afford it to hire private reporters, the court must ensure that indigent litigants receive access to an official verbatim record. Despite this, the petitioners alleged and the courts largely conceded that a chronic shortage of court reporters had rendered this guarantee largely ineffective. Some superior courts responded by issuing general orders allowing electronic recording in certain cases involving fundamental rights, but these policies were limited in scope and not uniformly adopted.The Supreme Court of California reviewed this original proceeding and held that, under the in forma pauperis doctrine articulated in *Jameson v. Desta*, superior courts have a ministerial duty to provide indigent litigants, upon request, with meaningful access to an official verbatim record of proceedings in all civil matters. This duty includes using electronic recording if neither an official nor a private court reporter is available, notwithstanding statutory restrictions. The court issued a writ of mandate directing the respondent superior courts to comply with this obligation. Each party was ordered to bear its own costs. View "Family Violence Appellate Project v. Super. Ct." on Justia Law
P. v. Demolle
An 11-year-old girl disappeared while visiting her parents in Oakland in July 1999 and was found dead the next day. Investigators discovered she had been raped and strangled. Within weeks, the defendant, a nearby resident, confessed to the crime after matching DNA evidence was found. In his confession, the defendant described luring the victim into his apartment, assaulting and killing her, and disposing of her body. The prosecution further corroborated the confession with testimony from a neighbor and other witnesses, and confirmed the DNA link. The defense did not present evidence at the guilt phase but presented mitigating evidence at the penalty phase, including character witnesses and information about the defendant’s background.The Superior Court of Alameda County conducted the trial. Before trial, the court denied the defendant’s motion to suppress evidence related to the police’s collection of his blood sample and confession, finding the encounter to be consensual and not a detention under the Fourth Amendment. The defendant was convicted of first-degree murder with special circumstances and sentenced to death. His post-trial motions, including those to discharge a juror and for a mistrial based on alleged juror bias, were denied.The Supreme Court of California reviewed the case on automatic appeal. The court held that the defendant was not unlawfully detained before consenting to the blood draw, that evidence obtained was admissible, and that no juror bias or improper admission of evidence rose to the level of reversible error. The court also addressed and rejected challenges to victim impact evidence, admission of unadjudicated criminal acts, and claims of constitutional violations in the penalty phase, including a claim under California’s Racial Justice Act regarding the prosecutor’s language. The judgment, including the death sentence, was affirmed. View "P. v. Demolle" on Justia Law
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P. v. Chhuon
Two defendants were jointly tried before separate juries for a series of violent crimes committed in Sacramento and Pomona in 1995. These included the robbery and murders of members of the Le family, the attempted murder of Quyen Luu, a burglary, an attempted robbery, and the murder of Miguel Vargas Avina with the attempted murder of Rodolfo Huerta. Both were also implicated in an uncharged murder (Bun) and alleged to have acted for the benefit of a criminal street gang. The prosecution relied on eyewitnesses, accomplice testimony, forensic evidence, and admissions from the defendants. The defense challenged witness identifications, introduced expert testimony on eyewitness reliability, and presented extensive mitigating evidence about the defendants' traumatic backgrounds.The Los Angeles County Superior Court allowed the charges from different counties to be joined under Penal Code section 790(b), leading to a joint capital trial. Both men were convicted of all charges and special circumstance allegations, and each jury returned a verdict of death. The trial court entered death judgments for both, finding true additional special circumstances.The Supreme Court of California reviewed the case automatically. For one defendant, the court affirmed the judgment except for vacating the gang enhancement finding, due to legislative changes that barred the use of the charged offense to establish a pattern of criminal gang activity. For the other defendant, the court reversed the judgment in its entirety. It held that defense counsel's closing argument conceding guilt on the defendant’s behalf, over his express objection, violated the defendant’s constitutional right to decide the objective of his defense, as articulated in McCoy v. Louisiana (2018). This error was deemed structural, requiring automatic reversal of all convictions and enhancements for that defendant. The case was remanded for further proceedings as to both defendants as specified. View "P. v. Chhuon" on Justia Law
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People v. Stayner
The defendant used a false pretense to enter the motel room of Carole Sund, her daughter Juli Sund, and family friend Silvina Pelosso. Once inside, he brandished a gun, used duct tape to bind the three, and murdered Carole and Silvina by strangulation and suffocation. Over several hours, he sexually assaulted Juli, then kidnapped her, assaulted her again, and ultimately killed her by slitting her throat. Months later, he also kidnapped, murdered, and decapitated Joie Armstrong. The defendant confessed to these crimes in detail. Physical evidence and testimony corroborated his confession. Evidence related to the Armstrong murder, prosecuted federally, was introduced during the penalty phase.A jury in the Santa Clara County Superior Court convicted the defendant of three counts of first-degree murder and one count of kidnapping. The jury found true multiple enhancement allegations, including use of a deadly weapon and firearm, and five special circumstances: multiple murders, kidnapping murder, attempted rape murder, forcible oral copulation murder, and burglary murder. The jury found not true the alleged robbery-murder special circumstance. In a separate sanity phase, the jury found the defendant sane at the time of the offenses, and in the penalty phase, recommended the death penalty. The trial court denied motions for a new trial and sentence modification, imposing death plus a consecutive prison term.On automatic appeal, the Supreme Court of California reviewed numerous claims, including challenges to the admission of the defendant’s confession, claims of evidentiary and procedural error, allegations of juror misconduct, and arguments regarding the constitutionality of California’s death penalty scheme. The Court held that the confession was properly admitted, the evidentiary and procedural rulings were within the trial court’s discretion, and that there was no prejudicial juror misconduct or judicial bias. The Court also rejected constitutional challenges to the death penalty statute. The Supreme Court of California affirmed the judgment in its entirety. View "People v. Stayner" on Justia Law
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In re Kowalczyk
A man was arrested after attempting to purchase food at a restaurant using several credit cards, three of which were lost cards belonging to other individuals. When the first five cards were declined, he discarded them; the sixth card worked, but after a dispute with the manager over a refund, he left without the food and was later taken into custody. He was charged with multiple counts, including felony vandalism, identity theft, and petty theft. At arraignment, the trial court denied his motion for release on his own recognizance and set bail at $75,000, citing his extensive criminal history and past failures to appear. After further hearings, the trial court ultimately denied bail altogether.The defendant filed a petition for writ of habeas corpus in the California Court of Appeal, First Appellate District, Division Three, challenging the denial of bail. While the petition was pending, he entered a plea agreement, resulting in his release. The appellate court dismissed the petition as moot, but the Supreme Court of California directed the Court of Appeal to address unresolved constitutional questions regarding bail. The Court of Appeal issued a published opinion addressing the relationship between two California constitutional provisions on bail and whether a trial court may set bail above a defendant’s ability to pay. The appellate court's reasoning conflicted with another appellate decision, In re Brown.The Supreme Court of California reviewed the case to resolve these issues. It held that Article I, section 12, subdivisions (b) and (c), defines the exclusive circumstances under which bail may be denied in noncapital cases, and Article I, section 28(f)(3), can be harmonized with, but does not expand, these exceptions. The court further held that, except where pretrial detention is authorized, bail must be set in an amount reasonably attainable given the defendant’s circumstances; courts may not set bail at an amount that is objectively unattainable based solely on indigency. The Supreme Court affirmed the judgment of the Court of Appeal. View "In re Kowalczyk" on Justia Law
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P. v. Bertsch
Two defendants were implicated in the 1985 kidnapping, rape, and murder of a woman in California. Evidence showed that they were previously involved in a string of armed robberies and planned to escape law enforcement by stealing a vehicle from a shopping center parking lot. They kidnapped the victim, drove her hundreds of miles, sexually assaulted her, and killed her before disposing of her body in a canal. Forensic evidence, including eyewitness testimony and DNA analysis, linked both men to the crimes. Both were arrested years later after advances in DNA technology allowed for retesting of biological evidence.The Sacramento County Superior Court tried the defendants together with separate juries. Each was found guilty of murder, rape, and kidnapping, with special circumstances for kidnapping-murder, robbery-murder, and rape-murder. One defendant was also convicted of sodomy with a sodomy-murder special circumstance. Both were sentenced to death after separate penalty phase trials. The court also imposed various prison terms and restitution fines, staying the execution of the prison sentences.The Supreme Court of California reviewed the case on automatic appeal. It affirmed the convictions of both defendants and the death sentence for one. However, it reversed the death sentence for the second defendant, finding that subsequent changes in the law—specifically regarding the competency of defendants with mental illness to represent themselves—required reversal of his sentence, including the death judgment. The court also vacated any balance of restitution fines for both defendants, pursuant to recent statutory amendments. The case was remanded for further proceedings as to the sentencing of the second defendant. View "P. v. Bertsch" on Justia Law
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Constitutional Law, Criminal Law